Obviously depends on the use case, but since C++11 there is little to no pain involved in manual non-stack memory management. You clearly express the ownership semantics through things like std::unique_ptr and std::shared_ptr and if those make sense then everything works (minus problems like circular shared_ptr references, which exists in similar forms with GCs).
Yeah, I didn't elaborate this enough (because it wasn't really the main point). When I said "similar" I meant "things holding onto things they should no longer be holding onto", not circular referencing in particular.
I realize that the kind of bug that leads to effective memory leaks with GCs has its own equivalent in manual memory management, but my overall point was that neither manual memory management nor GCs make you immune to leaks from badly designed or incorrectly implemented data structures. Each takes some aspect(s) of pain away.
